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Jennifer Mak

Partner, Tax Litigation

Jennifer resolves tax controversies with a holistic view to deliver the best overall result.

Jennifer's practice encompasses all aspects of tax controversy and litigation.

Jennifer has represented clients in appeals before the Tax Court of Canada and Federal Court of Canada.  She regularly works on complex objections and audits for private companies and high-net-worth individuals involving international and domestic issues.  

Jennifer has successfully resolved tax controversies involving residence for tax purposes, GST/HST, applications for judicial review, shareholder and employee benefits. 

Jennifer is a mentor with the Federation of Asian Canadian Lawyers. Each year, she helps two Asian Canadian law students navigate the legal profession.  

Latest Insights

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The Strategic Choice After Reassessment

Comparing the CRA’s self-adjudication stage with independent oversight in appeal
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Insights

GAAR and Economic Reality: When Imperfect Structures Survive Scrutiny

GAAR and Economic Reality: When Imperfect Structures Survive Scrutiny

Key Takeaways Economic substance framed: The FCA upheld a constrained structure because it was positioned around real economic gains, not technical form. Whole-plan control: GAAR outcomes often...

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due...

Tips for Accountants Navigating Audits: Part 3

Tips for Accountants Navigating Audits: Part 3

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.One of the chapters in RTD3...

Tips for Accountants Navigating Audits: Part 2

Tips for Accountants Navigating Audits: Part 2

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.One of the chapters in RTD3...

Tips for Accountants Navigating Audits: Part 1

Tips for Accountants Navigating Audits: Part 1

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.One of the chapters in RTD3...

Navigating Unintended Tax Effects: Limited Rescission & Other Options

Navigating Unintended Tax Effects: Limited Rescission & Other Options

The Supreme Court of Canada, in Canada (Attorney General) v. Collins Family Trust,1 further clarifies when courts can grant equitable remedies of rectification or rescission.

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